The law
Which product groups the ESPR names as priorities
The EU ecodesign regulation names priority product groups such as steel and textiles. A priority list is a work plan, not a duty.
The Ecodesign for Sustainable Products Regulation (ESPR) names a list of priority product groups. The list covers iron and steel, aluminium, textiles, furniture, tyres, detergents, paints, lubricants, chemicals, some energy-related products and electronics.
A place on that list gives your product no duty and no date. It tells you that the European Commission intends to write a rule for that group at some point.
Two mistakes follow from a wrong reading. The first is to buy a passport system for a group that has no rule. The second is to read absence from the list as an exclusion.
The list, as a standards body publishes it
Warning: read this section before you quote the list. This site has not read Article 18(5) of ESPR in the Official Journal.
GS1 in Europe, a standards body, publishes the list and attributes it to that article. Its wording:
iron and steel; aluminium; textiles, in particular garments and footwear; furniture, including mattresses; tyres; detergents; paints; lubricants; chemicals; some energy related products; information and communication technology products and other electronics
The Ministry of Foreign Affairs and Trade (MFAT) gives a shorter version of the same list in its market report of October 2025. That report names steel, textiles and apparel, tyres, aluminium, furniture and mattresses.
So two sources carry the list, and both of them are summaries. The verified legal text on this site does not quote Article 18(5). Treat the list as an account of the law by a standards body, and not as quoted law.
The ESPR does not name GS1 anywhere. A search of the full regulation finds no mention of GS1, of Digital Link, of IEC 61406 or of a digital object identifier. Annex III of the regulation names the ISO/IEC 15459 series instead. See the legal basis.
A priority list is a work plan, not a duty
ESPR creates no passport duty for any specific product. Article 9 makes a passport a condition of market access. That condition applies only to a group that a delegated act covers.
As at 14 August 2026 the Commission has adopted no delegated act for any product group. So the priority list changes nothing for your product today. See what is a delegated act.
A delegated act sets its own scope, its own data fields and its own date. The priority list sets none of those three, and it shows only the order of the work.
The adoption years are projections, and none is a deadline
Two sources give years for some of the priority groups. Both sets are projections.
| Priority group | Commission indicative adoption | MFAT report, October 2025 |
|---|---|---|
| Iron and steel | Q4 2026 | 2026 |
| Textiles, garments and footwear | Q3 to Q4 2027 | 2027 |
| Aluminium | Q3 to Q4 2027 | 2027 |
| Tyres | Q3 to Q4 2027 | 2027 |
| Furniture | 2028 | 2028 |
| Mattresses | No year given | 2029 |
| Information and communication technology, and other electronics | 2029 | Not listed |
| Detergents, paints, lubricants and chemicals | No year given | Not listed |
| Some energy-related products | No year given | Not listed |
Every year above is the year the Commission plans to adopt a rule. None of them is a compliance date. The Commission marks its own timeline as indicative, and it says the timelines may change as the work progresses. MFAT's years are adoption years too, and its report gives no date on which a passport becomes mandatory.
After adoption, the European Parliament and the Council may object. A transition period then runs. Article 4(4) of ESPR sets that period at 18 months or more. The same article permits an earlier date in duly justified cases. So an adoption year of 2027 means a compliance date in 2029 at the earliest. How to read the timeline does the arithmetic for each group.
The Commission plans to adopt the iron and steel act first. Many sources give 2027 as a textile compliance date. That year is the planned adoption year. See textiles, garments and footwear.
Some priority groups have no year, and detergents get their duty from another law
Detergents, paints, lubricants, chemicals and energy-related products sit on the priority list with no adoption year in these sources. If you make a wool wash or an industrial lubricant, you have no date to plan for.
GS1 said in a webinar of 5 May 2026 that the initial priority list was longer. It said the Commission published its first working plan for the ecodesign regulation and energy labelling in April 2025. It said that plan set the priorities further. That is an industry account of a Commission document, and this site has not read the plan itself.
Detergents show why the list can mislead. A detergent passport duty comes from Regulation (EU) 2026/405, which is the detergents regulation, and not from the ecodesign programme. If you export a detergent, you find no date in that programme. See detergents and paints, lubricants and chemicals.
Absence from the priority list is not an exclusion
Two different lists sit in ESPR, and you get the wrong answer if you mix them. Article 1(2) says which products the regulation cannot reach. The priority list says which products the Commission works on first.
If Article 1(2) excludes your product, no ecodesign rule can ever reach it. If your product is only missing from the priority list, you face a delay at most.
| Your product | Where it sits | What it means |
|---|---|---|
| A merino jumper | On the priority list, under textiles | The Commission intends to write a rule. None exists yet. |
| A face cream | Inside ESPR scope, and not on the list | Cosmetics stay in scope. A later work plan can reach them. |
| A carton of wine | Excluded by Article 1(2) | The regulation does not reach it at all. |
| An e-bike battery | Not on the priority list | A duty applies from 18 February 2027, under another law. |
Batteries are not on the priority list. The first binding passport duty in EU law comes from the battery regulation, Regulation (EU) 2023/1542. Article 77 of that regulation applies from 18 February 2027. It covers each light means of transport battery, each electric vehicle battery, and each industrial battery with a capacity greater than 2 kilowatt hours. See batteries.
The exclusion list works differently. Food and feed are outside ESPR, and so are medicinal products, veterinary medicinal products, living plants and animals. Wine is a food, so wine is outside ESPR scope. Your other products can still be inside scope. See ESPR exclusions and food and feed are excluded.
Monitor for the delegated act, not for the year
- Find your product group in the list above.
- If your group is there, monitor for the delegated act, not for the year.
- If your group is not there, check the exclusion list in Article 1(2).
- If you sell one of the three battery categories, work to 18 February 2027.
- Ask your EU customer which data they need, and when.
Do not buy a passport system because a priority list names your group. Which products need a passport, and when shows which law gives each group its duty.
This site searched 104 New Zealand pages on 16 August 2026, and no New Zealand agency publishes a priority list of this type.
Read the MFAT market report at mfat.govt.nz, and read its years as adoption years. See what New Zealand agencies have said.
What this site searched, and what came back, is listed in what this site does not know.